SPCC Plan

SECTION 1Professional Engineer Certification

This Plan is reviewed and certified by a licensed Professional Engineer under 40 CFR 112.3(d). Building B is not a qualified facility under 112.3(g) (Section 4.4).

By means of this certification I attest:

1. That I am familiar with the requirements of 40 CFR Part 112;
2. That I or my agent have visited and examined the facility (site visit by the undersigned on February 24, 2026);
3. That the Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of 40 CFR Part 112;
4. That procedures for required inspections and testing have been established; and
5. That the Plan is adequate for the facility.

Attestation 112.3(d)(1)(vi) applies only to produced water containers subject to 112.9(c)(6). There are none at this facility; it is not applicable.

This certification in no way relieves the owner or operator of the duty to prepare and fully implement the Plan in accordance with 40 CFR Part 112 (112.3(d)(2)).

SECTION 2Management Approval and Plan Availability

2.1 Management approval (112.7, introductory paragraph)

This Plan has the full approval of Perry Industries, Inc. management at a level of authority to commit the necessary resources to fully implement it. Management commits the people, equipment, materials and outside contractor support described in this Plan, including the response capability in Section 9, and will provide the resources needed to correct deficiencies found during inspections, reviews and audits.

Local approval for Building B operations:

2.2 Person accountable for discharge prevention (112.7(f)(2))

Dana Scully, EHS Manager, Building B, is designated as the person accountable for discharge prevention at this facility. She reports to Hari Seldon, Plant Manager, who reports to Mike Perry. Her duties under this Plan are to keep the Plan current, schedule and review inspections and tests, run the annual discharge prevention briefing, make or direct the agency notifications in Section 9, and track corrective actions to completion.

2.3 Plan location and availability (112.3(e))

Building B is attended more than four hours per day, so a complete copy of this Plan is kept at the facility: the master copy in the Building B EHS office and a controlled copy in the control room. The Plan is available to the EPA Regional Administrator for on-site review during normal working hours.

SECTION 3Plan Review and Amendment

3.1 Amendment for facility changes (112.5(a))

This Plan will be amended when there is a change in facility design, construction, operation, or maintenance that materially affects the potential for a discharge as described in 112.1(b). Examples include commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; and revision of standard operation or maintenance procedures. Each amendment is prepared within six months of the change and implemented as soon as possible, but not later than six months after the amendment is prepared.

Changes at Building B are routed through the management of change (MOC) process run by Doug Heasley. The MOC form asks whether the change affects any oil container, oil piping, containment, drainage or oil-handling procedure. If it does, the MOC is copied to Dana Scully, who decides whether a Plan amendment is needed.

3.2 Five-year review (112.5(b))

The owner or operator completes a review and evaluation of this Plan at least once every five years. As a result of the review, the Plan is amended within six months to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge as described in 112.1(b). Any amendment is implemented as soon as possible, but not later than six months after it is prepared. Completion of each review is documented in Table 3-1 with a signed statement in the form given in 112.5(b): “I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result.”

Table 3-1. Five-year review log (112.5(b))

3.3 Professional Engineer certification of technical amendments (112.5(c))

Every technical amendment to this Plan is certified by a licensed Professional Engineer in accordance with 112.3(d). Technical amendments are recorded in Table 3-2. Non-technical (administrative) changes such as names and phone numbers are recorded in Table 3-3.

Table 3-2. Technical amendment log (112.5(a) and (c))

Table 3-3. Administrative change log (no PE certification needed)

SECTION 4General Facility Information

4.1 Facility identification

4.2 Facility boundaries (112.2)

The Perry Industries campus (about 22 acres) has three buildings. Under the 112.2 definition of facility, contiguous buildings under the ownership or operation of the same person may be considered separate facilities. Each building is operated separately and is treated as its own SPCC facility:

• Building A — SYNTO Group, LLC (R&D). No oil container of 55 gallons or more; not subject to an SPCC Plan.
• Building B — Perry's Awesomeness Factory, operated by Perry Industries, Inc. This Plan.
• Building C — Honey Badger Logistics, LLC. Separate Tier I qualified facility Plan (self-certified January 12, 2026).

The Building B facility includes the building, the flammable tank farm (T-1 and T-3), the flammable/oil tank truck unloading pad, the GEN-1 emergency generator and base tank in the south yard, the TX-1 and TX-2 transformers south of the building, and the piping between them.

4.3 Applicability (112.1)

Building B is a non-transportation-related onshore facility that stores and uses oil. Because of its location on the north shore of Lake Tiberius, with storm drainage running to Outfall 001 and the lake, it could reasonably be expected to discharge oil in quantities that may be harmful (40 CFR Part 110) into navigable waters or adjoining shorelines (112.1(b)). The 112.1(d)(2) exemption does not apply: the aggregate aboveground oil storage capacity, counting only containers of 55 gallons or more, is 12,030 gallons, more than 1,320 gallons. The completely buried oil storage capacity is zero.

4.4 Certification basis (112.3(d) and 112.3(g))

A Tier I or Tier II qualified facility must have an aggregate aboveground oil storage capacity of 10,000 gallons or less (112.3(g)(2)), and a Tier I facility may have no single container larger than 5,000 gallons (112.3(g)(1)). Building B has 12,030 gallons in aggregate, and the T-4 GEN-1 base tank holds 6,000 gallons. Building B is not a qualified facility, so this Plan is certified by a Professional Engineer under 112.3(d).

4.5 Facility response plan determination (112.20(e))

Building B does not transfer oil over water to or from vessels, and its total oil storage capacity (12,030 gallons) is far below both 42,000 gallons and 1 million gallons. It does not meet the substantial harm criteria in 112.20(f)(1) and is not required to prepare a facility response plan. The certification form from Appendix C, Attachment C-II, is completed in Appendix H. Because no response plan has been submitted under 112.20, this Plan includes the information required by 112.7(a)(4) and (a)(5).

4.6 Discharge history

Building B has had no discharge as described in 112.1(b) in the three years before the certification date of this Plan. Discharges, failures and malfunctioning components found after that date are recorded on the spill report form (Appendix F) and covered in the annual briefing (Section 13).

SECTION 5Conformance With Part 112 and Cross-Reference

5.1 Conformance discussion (112.7(a)(1)) and cross-reference

This Plan follows the sequence of 112.7 and then 112.8. Table 5-1 lists each applicable paragraph of Part 112, states whether the facility conforms, and gives the section of this Plan that addresses it. Each section also discusses conformance in its own text.

Table 5-1. Conformance and cross-reference to 40 CFR Part 112

5.2 Deviation with equivalent environmental protection (112.7(a)(2))

Requirement. 112.8(b)(3) calls for drainage from undiked areas with a potential for a discharge to flow into ponds, lagoons, or catchment basins designed to retain oil or return it to the facility. If that is not done, 112.8(b)(4) calls for a diversion system at the final discharge of all ditches inside the facility that would retain oil in the facility.

Reason for nonconformance. The campus storm sewer collects runoff from all three buildings and discharges through Outfall 001 directly to Lake Tiberius. There is no on-site catchment basin and no diversion structure at the outfall. Undiked areas at Building B with a potential for discharge are the aboveground T-3 product piping outside the dike wall, the T-4 fill connection at GEN-1, where the delivery truck parks on the South Drive, and the paved yard around the unloading pad, GEN-1 and the transformers.

Alternate methods and how equivalent protection is achieved. These measures keep oil from reaching SI-1 and SI-2 and the outfall:

1. Every oil container and piece of oil-filled equipment has passive containment that holds its full contents: the tank farm dike, the T-4 double wall, curbed transformer pads, and spill pallets (Section 11).
2. The flammable/oil unloading pad (20 ft x 60 ft) is curbed and drains to a 3,500-gallon sump that holds more than the largest truck compartment (3,000 gallons). The pad sump has no gravity outlet (Section 11.6).
3. Every oil delivery and transfer is attended from start to finish by a trained Perry employee who can stop flow immediately (Section 7).
4. Drain covers are staged at SK-2 and SK-4 (for SI-1) and at SK-6 (for SI-2). The SK-6 cover is placed over SI-2 before every diesel delivery to T-4. Oil-handling personnel are trained to place the covers within the first minutes of a discharge (Sections 9 and 13).
5. T-3 product piping outside the dike is aboveground, protected from vehicles, and walked down monthly; a leak is isolated by closing the T-3 outlet valve inside the dike (Section 20).
6. A trained 12-member Emergency Response Team works both shifts, and Sheaves Environmental Response provides 24-hour cleanup support (Section 9).

Taken together, these measures stop and hold a discharge before it reaches the storm system, which is the purpose of 112.8(b)(3) and (b)(4). This deviation is reviewed at each five-year review; installing a shutoff or diversion at Outfall 001 is the technology to evaluate.

5.3 Facilities, procedures, methods or equipment not yet fully operational

None. Every measure described in this Plan was in place and operating on the certification date.

SECTION 6Facility Layout, Diagram and Oil Containers

6.1 Physical layout (112.7(a)(3))

Building B is the center building on the campus, entered from Perry Parkway at Gate 2. Inside the building are the Awesomeness and Brilliance blending lines, the Thunderbolt Solvent System (reflux kettle R-101), the control room, the maintenance shop, packaging and finished goods, the lab/QC area and office, and the 90-day hazardous waste accumulation area (HWA) on the south side.

Outside, the flammable tank farm is northeast of the building. Its 60 ft x 50 ft concrete dike holds T-1 (Thunderbolt, isopropyl alcohol, not oil) and T-3 (white mineral oil). Product piping runs from the tank farm west into the building. The flammable/oil tank truck unloading pad is just south of the tank farm on the Building B access road, with storm inlet SI-1 just southwest of it. GEN-1 with its T-4 diesel base tank, and transformers TX-1 and TX-2 on curbed pads, are in the south yard below Doors B-4 and B-5; SI-2 is just south of GEN-1. SI-1 and SI-2 drain through the campus storm sewer to Outfall 001 and Lake Tiberius (campus site plan PI-C-001, Figure 2).

The ammonia storage area east of the building (T-2, Polyjuice Base, in its own 40 ft x 40 ft dike with drain valve DV-2, about 170 ft from the tank farm dike) and its separate ammonia unloading pad hold no oil and are not part of this Plan. They are shown on Figure 1 for location only.

The facility diagram is Figure 1 in Appendix A (drawing PI-B-101). It marks the location and contents of each fixed oil container, the storage area for drums and the tote, the unloading pad (transfer station), the GEN-1 fill, connecting piping, storm inlets, spill kits and drain covers. Figure 2 (drawing PI-C-001) shows the campus storm sewer and Outfall 001. There are no underground tanks to mark as exempt under 112.1(d)(4) and no intra-facility gathering lines.

6.2 Oil container inventory (112.7(a)(3)(i))

Table 6-1. Oil containers counted toward aggregate capacity (55 gallons or more)

Completely buried oil storage capacity: 0 gallons. Oil in drums and the tote is the only portable oil storage. The maintenance shop may hold up to six drums and one tote at a time; if more are needed, this table and the containment in Section 11 are updated first.

White mineral oil is oil under Part 112: the 112.2 definition of oil names mineral oils, and the definition of petroleum oil names mineral oil. The same is true of transformer oil.

Table 6-2. Containers and equipment not counted, and why

SECTION 7Discharge Prevention — Routine Handling of Oil

112.7(a)(3)(ii) requires the Plan to address discharge prevention measures, including procedures for routine handling of products (loading, unloading, and facility transfers). The procedures below are written operating procedures for Building B. Only employees trained under Section 13 may attend an oil transfer.

7.1 Tank truck delivery of white mineral oil to T-3

White mineral oil is delivered by Arrakis Fuel & Lubricants in tank trucks with compartments of up to 3,000 gallons. Deliveries are received on day shift Monday–Friday only. The truck parks on the curbed flammable/oil unloading pad south of the tank farm and pumps through a hose to the T-3 fill connection on the dike wall. The pad also serves T-1 (Thunderbolt), which is not oil.

1. Before the truck arrives, the receiving operator checks the T-3 level in the control room and confirms that the tank has room for the full delivery plus a margin of at least 10 percent of tank capacity. If there is not room, the delivery is refused or split.
2. The operator checks that the unloading pad sump is empty and that the pad drain covers and SK-4 are in place, and tests the T-3 high-level alarm with the test button.
3. The truck is directed onto the pad, the engine is shut off, the parking brake is set, and wheel chocks are placed. A "Stop — Hose Connected" sign is placed at the cab.
4. The operator and driver check the hose, couplings and gaskets, connect the hose, confirm the correct fill line by its label ("T-3 WHITE MINERAL OIL"), and open the fill valve.
5. The operator stays at the transfer for the entire delivery and watches the tank level and the hose. The control room watches the T-3 level and high-level alarm.
6. At the end of the delivery the driver stops the pump, the fill valve is closed, the hose is drained back to the truck, and the fill connection is capped and locked.
7. Before the truck leaves, the driver and operator check the lowermost drain and all outlets of the truck for leaks, and the chocks are removed only after the hose is fully disconnected and stowed.
8. The operator records the delivery volume and the before and after tank levels on the delivery log.

7.2 Diesel delivery to T-4 (GEN-1)

Diesel for T-4 is delivered by Arrakis Fuel & Lubricants on day shift Monday–Friday only. The unloading pad serves T-1 and T-3 only, so the diesel truck parks on the South Drive beside GEN-1 and pumps through a short hose to the T-4 fill connection. Steps 1 and 3 through 8 of Section 7.1 apply, with these additions:

• The operator reads the T-4 level gauge and confirms room for the delivery, and tests the T-4 high-level alarm at the fill connection before the delivery starts.
• This transfer area is not curbed. Before the hose is connected, the operator places the drain cover from SK-6 over SI-2 and stages SK-6 sorbent socks at the truck, and watches the full hose length during the delivery.
• The operator checks the T-4 interstitial monitor reading before and after the delivery and records it.

7.3 Transfers from T-3 to the Brilliance line

• T-3 is pumped to the Brilliance line blend tanks (BR-1 to BR-3) by the T-3 transfer pump through aboveground piping. Transfers are started from the control room by the operator on duty for each batch.
• The T-3 outlet valve inside the dike is opened only for transfers and is closed at the end of the second shift and whenever production is not running.
• The operator walking the line checks the piping, valves and pump seal at the start of each shift that uses T-3.

7.4 Drums and tote in the maintenance shop

• Drums and the tote arrive full from the supplier and are moved by forklift with the drum attachment or on a pallet, closed, and set directly on the spill pallets. They are not refilled on site.
• Oil is dispensed only through a closed valve or hand pump into a container under 55 gallons, with a drip pan under the valve.
• Bungs and lids are kept closed except while dispensing. Empty drums are closed and removed from the shop.

7.5 Transformers TX-1 and TX-2

Only qualified electrical workers or the utility service contractor sample, top off or drain transformer oil. Any work that opens the oil system is done with absorbent pads and a drip pan in place, and the pad is checked for oil before the job is closed out.

7.6 General rules

• No oil transfer is left unattended.
• No oil is put into a storm inlet, floor drain or sanitary drain.
• Leaks and drips found during any transfer are stopped and cleaned up before the job is closed, and reported to the control room.
• Contractors who handle oil at Building B are briefed on this Plan before work starts.

SECTION 8Discharge or Drainage Controls

112.7(a)(3)(iii) requires the Plan to address discharge or drainage controls such as secondary containment around containers and other structures, equipment and procedures for the control of a discharge. Table 8-1 summarizes the controls for each area. Capacities and calculations are in Section 11; drainage is covered in Section 18.

Table 8-1. Discharge and drainage controls by area

SECTION 9Discharge Response Procedures

This section covers 112.7(a)(3)(iv), (a)(3)(v), (a)(3)(vi), (a)(4) and (a)(5). It is organized for use during an emergency. Forms are in Appendices F and G. When a discharge also involves isopropyl alcohol or hazardous waste, the Campus Emergency Action Plan (Rev. 4), the Building B LQG contingency plan (Rev. 3) and the ERT procedures apply at the same time.

9.1 Immediate actions

Table 9-1. Who does what in the first minutes

9.2 Response organization

The facility response coordinator is Steve Resko, ERT Leader. He is on site on day shift. If he is not on site, the alternates take over in this order: Marty McFly, Night Shift Supervisor (on site 2:30–11:00 p.m.), Jenn Resko, Montgomery Scott. After 11:00 p.m. and on weekends, Gate 2 security calls in this order until one answers: Marty McFly, Steve Resko, Jenn Resko, Montgomery Scott; the Emergency Coordinator reached calls back the ERT and notifies Dana Scully. The same people serve as Emergency Coordinators under the LQG contingency plan. The response is directed from the Building B control room, which has telephones, the plant radio system and the alarm panels.

The Building B Emergency Response Team has 12 members across both shifts, trained as hazardous materials technicians under 29 CFR 1910.120(q)(6)(iii). The ERT handles oil discharges that are beyond incidental cleanup or that involve Thunderbolt (T-1) in the tank farm. Sheaves Environmental Response provides 24-hour cleanup, vacuum truck service and waste removal under an agreement with Perry Industries. New Mos Eisley Fire Department Station 7, about 2 miles away, has a hazmat team and responds to fires and releases that need outside help.

9.3 Contact list (112.7(a)(3)(vi))

Table 9-2. Emergency contact list

9.4 Spill response equipment

Spill kits are marked on Figure 1. Contents and absorbent capacity (the total gallons the kit’s sorbents hold) are listed in Table 9-3. Kits are inspected monthly with the SPCC checklist (Appendix B) and restocked by Montgomery Scott.

Table 9-3. Spill kits in or near oil areas (SK-1 and SK-5 serve adjacent non-oil areas and are listed for completeness)

Other equipment available: ERT response trailer and gear (ERT room), portable pump and drums for recovering oil, the Building B forklift for moving containers, and Sheaves Environmental Response vacuum trucks and boom on call.

9.5 Notification — when to call

Table 9-4. Notifications

9.6 Information to give when reporting (112.7(a)(4))

The person reporting uses the Discharge Notification Form (Appendix G) and gives:

• The exact address or location and phone number of the facility: Perry's Awesomeness Factory (Building B), 1 Perry Parkway, New Mos Eisley, on the north shore of Lake Tiberius; main office (555) 555-0108, control room (555) 555-0110, or the caller's call-back number.
• The date and time of the discharge.
• The type of material discharged.
• Estimates of the total quantity discharged.
• Estimates of the quantity discharged as described in 112.1(b) (to the lake or its shoreline).
• The source of the discharge.
• A description of all affected media (pavement, soil, storm sewer, Lake Tiberius).
• The cause of the discharge.
• Any damages or injuries caused by the discharge.
• Actions being used to stop, remove, and mitigate the effects of the discharge.
• Whether an evacuation may be needed.
• The names of individuals and/or organizations who have also been contacted.

9.7 Response actions by scenario

Table 9-5. Scenario response actions

9.8 Written report to EPA after certain discharges (112.4)

Dana Scully submits the information below to the EPA Regional Administrator within 60 days from the time the facility becomes subject to 112.4, which happens when the facility:

• discharges more than 1,000 U.S. gallons of oil in a single discharge as described in 112.1(b), or
• discharges more than 42 U.S. gallons of oil in each of two discharges as described in 112.1(b), occurring within any twelve-month period.

The quantities are those discharged as described in 112.1(b) — into or upon navigable waters or adjoining shorelines. The report contains (112.4(a)(1)–(9)):

1. Name of the facility;
2. Name of the owner or operator;
3. Location of the facility;
4. Maximum storage or handling capacity of the facility and normal daily throughput;
5. Corrective action and countermeasures taken, including a description of equipment repairs and replacements;
6. An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary;
7. The cause of the discharge, including a failure analysis of the system or subsystem in which the failure occurred;
8. Additional preventive measures taken or contemplated to minimize the possibility of recurrence; and
9. Such other information as the Regional Administrator may reasonably require pertinent to the Plan or discharge.

A complete copy of everything sent to the Regional Administrator is also sent to the state agency in charge of oil pollution control activities (112.4(c)). This written report does not replace the immediate NRC notification in Section 9.5.

9.9 Disposal of recovered materials (112.7(a)(3)(v))

• Recovered oil, used sorbents, contaminated soil and wash water are put in closed, labeled containers (drums or a Sheaves vacuum truck) at the point of cleanup.
• Dana Scully makes a hazardous waste determination under 40 CFR 262.11 before disposal. Oil mixed with Thunderbolt from the tank farm dike may be ignitable (D001) and is then managed in the Building B HWA as hazardous waste under the LQG contingency plan.
• Part 279 applies only to used oil. 40 CFR 279.1 defines used oil as “any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities.” Oil recovered from equipment in service — transformer oil from TX-1 or TX-2, and in-service lube or hydraulic oil — that is not hazardous waste is managed as used oil under 40 CFR Part 279.
• Spilled new product that has not been in service — white mineral oil from T-3, diesel from T-4, and oil from unopened drums or the tote — is not used oil. Dana Scully makes a waste determination for it, and it goes to recycling or disposal through Sheaves Environmental Response. Used sorbents and other oily debris are handled the same way.
• Shipping papers, manifests and disposal receipts are kept with the spill report.

9.10 After the response

• Restock spill kits and clean or replace response equipment before normal operations resume.
• Complete the spill report (Appendix F) within 5 working days. Dana Scully reviews the cause and corrective actions.
• Decide whether the discharge triggers a 112.4 report (Section 9.8) or a Plan amendment (Section 3.1).
• Cover the discharge, its cause and the corrective actions at the next annual briefing (Section 13).